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of the methodology that petitioners contend they used, as re-
flected on such workpapers, to estimate the gambling losses that
they claim they incurred at Harrah’s on August 13 and 14 and
September 4, 1999.10 We are unwilling to rely on Mr. Hartsock’s
self-serving and uncorroborated testimony and the self-serving
and uncorroborated workpapers that petitioners prepared in order
to establish that they incurred gambling losses at Harrah’s on
certain dates during 1999. Petitioners presented no evidence in
9(...continued)
time interval between 10:22 p.m. and 10:51 p.m. is 29 minutes,
not 19 minutes. Moreover, Mr. Hartsock testified that he would
have been able to wager within a minute only $300 in a $25 slot
machine, or at most $5,700 in a 19-minute period and at most
$8,700 in a 29-minute period.
An additional example of the unreliability of petitioners’
workpapers is that one of those workpapers indicates that peti-
tioners estimated that Mr. Hartsock wagered in a $100 slot
machine, and lost before any reduction for time spent not wager-
ing, $42,000 during what they computed to be a 35-minute period
between 1:35 a.m. and 2:00 a.m. on Sept. 5, 1999. However, the
time interval between 1:35 a.m. and 2:00 a.m. is 25 minutes, not
35 minutes.
10For example, petitioners have failed to establish that
they gambled during each time interval between gambling winnings
shown on the respective Harrah’s substitute Forms W-2G with
respect to Aug. 13 and 14 and Sept. 4, 1999, at the same slot
machine from which they received gambling winnings at the end of
each such time interval, as shown on such forms. Nor have
petitioners persuaded us that they would have been able to wager
within a minute the respective amounts that they claim they
wagered in a $100 slot machine (i.e., $1,200) and a $25 slot
machine (i.e., $300). In addition, petitioners did not provide a
specific and acceptable explanation as to how they calculated the
respective amounts of time that they assert they did not spend
playing slot machines to smoke cigarettes, get drinks, and talk
with others, which time they assert they used to reduce their
claimed gambling losses at Harrah’s.
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